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Disabilities and Enrollment Status

Financial aid administrators are occasionally asked to allow a student with a disability to take a reduced course load and yet still be considered a full-time student for financial aid purposes. This can affect the amount of Pell Grant funding a student is eligible to receive. Although colleges are required to make "reasonable accommodations" for disabled students, such an accommodation is specifically precluded by guidance published by the US Department of Education.

The Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1973 require postsecondary institutions are required to provide reasonable accommodations for a student's disability, so long as they don't constitute undue hardship. Reasonable accommodations must be related to the student's disability, and can include extended time for testing and reduced course load, in addition to the usual architectural modifications.

Schools can and should use professional judgment to include in cost of attendance (or make other adjustments to income and assets) expenses related to the student's disability (see HEA sections 472(9) and 479A(b)(2)).

With regard to a reduced course load, 34 CFR 668.34 states that a school may make exceptions to the SAP policy when a student's failure to meet the SAP requirements is due to "other special circumstances", which can include disabilities. However, this does not permit the school to count the reduced course load as though it were a full-time load for financial aid purposes.

The Department has published specific guidance with regard to the Pell Grant program (where the grant amount depends on enrollment status) that prohibits schools from using a full-time status that is below the minimum standard set by the school for other students or below the minimum regulatory requirements. For example, the Federal Student Aid Handbook states, in the section concerning enrollment status:

Your definition of a full-time workload for a program must be used for all students enrolled in that program and must be the same definition for all SFA-related purposes, including loan deferments. You can't accommodate a student with a learning disability or other handicap by allowing the student a full-time enrollment status lower than the minimum standard.

Current regulations determine enrollment status by program, and require all students in a program to be subjected to the same definition of full-time status. No exception is allowed for disabled students. The Department has considered relaxing the standard for disabled students, but determined that such a change would cause disabled students to run out of aid more quickly. Such a policy change would end up hurting disabled students, instead of helping.

Note that the school does not need to provide the student with the requested accommodation or the best accommodation, so long as the provided accommodation is effective. Permitting a reduced course load while not counting it as though it were full-time is usually an effective reasonable accommodation.

Note also the "undue hardship" exception. This allows schools to avoid accommodations that are too expensive, fundamentally alter the nature of the education program, or which have a substantial negative impact on other students. In particular, the school is not required to lower or substantially modify essential educational requirements, such as waiving courses required for a degree.

On the other hand, nothing prevents the student from enrolling with a full-time course load and the school waiving SAP requirements because of the student's disability.

A good source of additional information is the US Department of Education's Office of Civil Rights.

The Association for Higher Education and Disability (AHEAD) is lobbying Congress to allow schools to use alternate definitions of enrollment status for disabled students.